1. The District of Columbia was a State, as defined by Title 18, United
States Code, Section 666(d)(4), that received federal assistance in excess
of $10,000 during each calendar year in 2007,, 2008 and 2009.

2. Defendant HARRY L. THOMAS, JR. was an agent of the District of
Columbia, whose duties as an elected member of the District of Columbia
Council included voting on matters before the Council, including voting on
the District of Columbia's annual budget and legislation concerning the
distribution of public funds, among other things.

3. From at least as early as in or about April 2007 and continuing
until at least in or about February 2009, in the District of Columbia,
defendant HARRY L. THOMAS, JR. embezzled, stole, obtained by fraud,
without authority knowingly converted to the use of a person not the
rightful owner, and intentionally misapplied property worth at least
$5,000 and owned by, under the care of, under the custody of, and under
the control of the District of Columbia, that is, $353,500 in District of
Columbia funds.

(Theft Concerning Programs Receiving Federal Funds, in Violation of
Title 18, United States Code, Section 666(a)(1)(A))

COUNT TWO (Filing a False Tax Return)

4. From on or about October 10, 2008 through on or about May 12, 2011,
in the District of Columbia, defendant HARRY L. THOMAS, JR., a resident of
the District of Columbia, did willfully make and subscribe to U.S.
Individual Income Tax Returns for the calendar years 2007, 2008 and 2009,
which were verified by a written declaration that they were made under
penalties of perjury and which he did not believe to be true and correct
as to every material matter. The income tax returns that were filed with
the Internal Revenue Service reported that the total income for defendant
HARRY L. THOMAS, JR. was $108,593 for 2007, $115,133 for 2008, and
$120,099 for 2009, and that he had no other income which was not described
in the returns, when in truth and in fact, as he then and there well knew
and believed, his total income was greater than the amounts reported, in
that during the years 2007, 2008 and 2009 he had received the following
amounts of additional unreported income: $25,000 in 2007, $278,000 in
2008, and $43,000 in 2009.

(Filing a False Return, in Violation of Title 26, United States Code,
Section 7206(1))

FORFEITURE ALLEGATION

1. The violation alleged in Count One of this Information is realleged
and incorporated by reference herein for the purpose of alleging
forfeiture to the United States of America pursuant to the provisions of
Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United
States Coe, Section 2461(c).

2. As a result of the offense alleged in Count One of this Information,
defendant HARRY L. THOMAS, JR. shall forfeit to the United States the
following property:

3. By virtue of the commission of the felony offense charged in Count
One of this Information, any and all interest that defendant HARRY L.
THOMAS, JR. has in this property constituting, or derived from, proceeds
obtained directly or indirectly, as the result of such offense is vested
in the United States and hereby forfeited to the United States pursuant to
Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United
States Code, Section 2461(c). )

(Criminal Forfeiture, in violation of Title 18, Unitd States Code,
Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c))